Code Section 957 definition
Examples of Code Section 957 in a sentence
The Company is not and has never been a “personal holding company” (within the meaning of Code Section 542), a shareholder in a “controlled foreign corporation” (within the meaning of Code Section 957), in a “foreign personal holding company” (within the meaning of Code Section 552), or in a “passive foreign investment company” (within the meaning of Code Section 1297), or an owner in any entity treated as a partnership or disregarded entity for federal income Tax purposes.
Neither OCW nor any of its Subsidiaries has ever owned an interest in, (i) a “passive foreign investment company” within the meaning of Code Section 1297, or (ii) a “controlled foreign corporation” within the meaning of Code Section 957.
None of the Acquired Companies is or has ever been a “personal holding company” (within the meaning of Code Section 542), or a shareholder in a “controlled foreign corporation” (within the meaning of Code Section 957), a “foreign personal holding company” (within the meaning of ▇▇▇ Section 552), or a “passive foreign investment company” (within the meaning of Code Section 1297).
No Company has ever been a "personal holding company" (within the meaning of Code Section 542), a shareholder in a "controlled foreign corporation" (within the meaning of Code Section 957), or in a "passive foreign investment company" (within the meaning of Code Section 552), or an owner in any entity treated as a partnership or disregarded entity for federal income tax purposes.
Other than LifeMap Sciences, neither the Company nor any other Acquired Company owns any interest in any “controlled foreign corporation” (as defined in Code Section 957).
The Company is not and has never been a “personal holding company” (within the meaning of Code Section 542), a shareholder in a “controlled foreign corporation” (within the meaning of Code Section 957), in a “foreign personal holding company” (within the meaning of Code Section 552), or in a “passive foreign investment company” (within the meaning of Code Section 1297), or an owner in any entity treated as a partnership or disregarded entity for U.S. federal income tax purposes.
The Company is not and has never been a “personal holding company ” (within the meaning of Code Section 542), a shareholder in a “controlled foreign corporation ” (within the meaning of Code Section 957), in a 7/3393869.1 - 27 - “foreign personal holding company ” (within the meaning of Code Section 552), or in a “passive foreign investment company ” (within the meaning of Code Section 1297), or an owner in any entity treated as a partnership or disregarded entity for federal income Tax purposes.
The Company is not and has never been a “personal holding company” (within the meaning of Code Section 542), a shareholder in a “controlled foreign corporation” (within the meaning of Code Section 957), in a “foreign personal holding company” (within the meaning of Code Section 552), or in a “passive foreign investment company” (within the meaning of Code Section 1297), or an owner in any entity treated as a partnership or disregarded entity for federal income tax purposes.
Neither the Company nor any of its Subsidiaries is a “controlled foreign corporation” as defined in Code Section 957, and neither the Company nor any of its Subsidiaries has had or will have any subpart F income within the meaning of Section 954 of the Code in any taxable year, including its current taxable year.
The Company (A) is not and has not been a ‘‘controlled foreign corporation’’ as defined in Code Section 957, (B) is not and has not been a “passive foreign investment company” within the meaning of Code Section 1297, and (C) does not have a permanent establishment (within the meaning of an applicable Tax treaty) or otherwise has an office or fixed place of business in a country other than the United States.